OSHA Inspection: CASTWELL PRODUCTS, LLC

Issued

Jun 12, 2014

Abate by

Jan 27, 2016

Penalty

Initial $5,670 · Current $5,670

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(c): An employee(s) was exposed to respirable crystalline quartz silica in excess of the 8-hour time weighted average limits as calculated using the formula listed in Table Z-3:     a) Castwell Products, LLC, Skokie, IL- An employee working in Department 20, at central shakeout table, and the DISA in the foundry was exposed to airborne concentrations of crystalline silica (quartz) at 0.967 mg/M3, approximately 1.79 times the Permissible Exposure Limit (PEL) of 0.539 mg/M3 as an 8-hour time-weighted average.  This exposure was derived from a sample taken over a 387 minute period during one shift on March 17, 2014. Zero exposure was assumed for the unsampled period of 93 minutes. This PEL was established to prevent silicosis and lung cancer.       b) Castwell Products, LLC, Skokie, IL- An employee operating a powered industrial vehicle in the foundry was exposed to airborne concentrations of crystalline silica (quartz) at 2.01 mg/M3, approximately 1.51 times the Permissible Exposure Limit (PEL) of 1.33 mg/M3 as an 8-hour time-weighted average. This exposure was derived from a sample taken over a 386 minute period during one shift on March 17, 2014. Zero exposure was assumed for the unsampled period of 94 minutes. This PEL was established to prevent silicosis and lung cancer.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 12, 2014

Abate by

Jan 27, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):    a) Castwell Products, LLC, Skokie, IL- Effective engineering and administrative controls were not instituted and maintained by the employer in Department 20, in the shakeout and the DISA area of the foundry to reduce employee exposure to crystalline silica (quartz) below the Permissible Exposure Limit (PEL). Employees working in the shakeout and DISA area of the foundry or operating powered industrial vehicles, including transfer trucks, in the area were exposed to crystalline silica in excess of the PEL.     See instance descriptions in item 2(a) of this citation.    Methods of engineering, administrative and work practice controls under these circumstances include but are not limited to:    1) Enforce the proper use of respirators. Ensure that an effective respiratory protection program in accordance with 1910.134 is being followed where employees are trained and respiratory protection is used correctly.       2) Seek expertise of a competent individual who regularly provides independent consulting service such as a ventilation expert for this or similar industries to conduct an assessment of the existing engineering control systems and make recommendations to improve the ventilation to reduce employee exposures.       3) Implement a more aggressive administrative control program including housekeeping of floors and other horizontal surfaces where deposited silica can be re-introduced into the general workplace air. Use dustless methods of cleaning such as vacuuming. General housekeeping should be intensified to mitigate dust accumulation that contain respirable particulates.      4) Perform periodic checks of the local exhaust ventilation system to ensure that the capture velocity is effective,   and that the system is functioning properly.        ABATEMENT NOTE:      STEP 1:  A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measure to control employee exposures to crystalline silica as referenced in the citation.  This plan shall include, at a minimum, target dates for the following action, which must be consistent with the dates required by this citation:      (1)  Evaluation of engineering/administrative controls;   (2)  Selection of the optimum control methods and completion of design;   (3)  Procurement, installation and operation of selected control measures;   (4) Testing and acceptance or modification/redesign of controls.      All proposed control measure shall be evaluated for each particular use by a competent industrial hygienist or other technically qualified persons(s).  30-day progress reports to OSHA are required during the abatement period.      Abatement date: 7/30/2014      STEP 3:  Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.      Abatement date: 09/11/2014    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 12, 2014

Penalty

Initial $5,670 · Current $0 Reduced

Hazardous substances 9010

General-duty citation text

29 CFR 1910.134(k)(1)(i): The employer did not ensure that each employee could demonstrate knowledge of why the respirator was necessary and how improper fit, usage, or maintenance could compromise the protective effect of the respirator:     (a) Castwell Products, LLC, Skokie, IL- Multiple employees exposed to crystalline quartz silica while performing various tasks such as driving powered industrial vehicles or transfer trucks, or in departments such as central shakeout, that require the use of respiratory protection were  wearing their disposable particulate respirators improperly.     No abatement documentation or certification required for this item.

Issued

Jun 12, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 9010

General-duty citation text

29 CFR 1910.134(k)(5)(ii): Retraining was not conducted when inadequacies in the employees' knowledge or use of the respirator indicated that the employee did not retain the necessary training or skill:     a) Castwell Products, LLC, Skokie, IL- Multiple employees exposed to crystalline quartz silica while performing various tasks such as driving powered industrial vehicles or transfer trucks, or in departments such as central shakeout, that require the use of respiratory protection were wearing their disposable particulate respirators improperly.       No abatement documentation or certification required for this item.